THE THRIVE ACT
BACKGROUND
The current US FDA regulatory process is designed for medical products that target specific diseases already present in patients. This framework does not suit products that extend healthspan, which often prevent diseases and/or target multiple age-related diseases at once. To demonstrate that healthspan products are effective, sponsors need to run complex, long, and expensive clinical trials. Few companies invest in this risky regulatory pathway, hindering healthspan innovation.
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To address these difficulties, The Kitalys Institute, in partnership with The Healthspan Action Coalition, created the THRIVE Act, which proposes a new, optional approval pathway for healthspan products without modifying or replacing existing regulations around non-healthspan products.
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To coordinate the review of healthspan products, the THRIVE Act proposes the FDA Center for Healthspan Products.
A NEW REGULATORY PATHWAY
The THRIVE Act regulatory pathway consists of three tiers of approval:
TIER 1
For products reasonably likely to increase healthspan
Requires a variety of clinical and preclinical evidence
Five years of market exclusivity
TIER 2
For products likely to increase healthspan
Requires at least one clinical trial, with other data as needed
Five additional years of market exclusivity
TIER 3
For products with substantial evidence of effectiveness
Requires well-controlled clinical trials with diverse, representative populations
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Five additional years of market exclusivity
Sponsors are encouraged to ultimately obtain Tier 3 approval for all products, according to the process below:
Tier 1 approval
Tier 1 approval
within one year of Tier 1 approval
Sponsor must begin clinical trial for Tier 2 application
Marketing
within ten years of marketing
within five years of marketing
Tier 3 approval
Tier 2 approval
within two years of Tier 2 approval
Tier 3 approval
Sponsor must begin clinical trial for Tier 3 application
If a product is unable to reach the next tier, it may be withdrawn or, provided it continues to be safe, accompanied by a disclosure of the limited evidence supporting it.
PRIORITY REVIEW VOUCHERS
The THRIVE Act proposes transferable priority review vouchers in the following cases:
EMERGING COMPANIES
a Breakthrough Healthspan Drug Designation, OR
first Tier 2 or 3 approval of a drug or supplement targeting two or more major chronic, age-related diseases
LARGE COMPANIES
a Breakthrough Healthspan Drug Designation, OR
first Tier 3 approval of a drug or supplement targeting two or more major chronic, age-related diseases
REPURPOSED GENERICS
Tier 2 or 3 approval for a repurposed generic drug (a drug originally approved for a non-healthspan indication, which the sponsor has repurposed for a healthspan indication)
ADDITIONAL INCENTIVES
In addition to the tiered regulatory pathway and priority vouchers, the THRIVE Act introduces the incentives below:
